Artis v. District of Columbia

Stephanie Artis (plaintiff) worked as a health inspector for the District of Columbia (DC) (defendant). Artis filed a federal Title VII employment-discrimination claim against DC and, in the same federal action, raised three related state-law claims under the federal court’s supplemental jurisdiction. The federal district court ultimately dismissed Artis’s Title VII claim and declined to continue exercising supplemental jurisdiction over the state-law claims. Artis refiled her state claims in state court 59 days later. DC moved to dismiss, arguing that Artis’s claims were time barred because she had failed to refile her state claims within the 30-day grace period provided by 28 U.S.C. § 1367(d), the federal supplemental-jurisdiction statute. Artis countered, arguing that (1) § 1367(d) tolled the relevant state statute of limitations; and (2) because the state statute of limitations had over two years left when Artis filed her federal action, Artis’s refiled state claims were not time barred. DC challenged, arguing that interpreting § 1367(d) as Artis argued would be unconstitutional because it would exceed Congress’s enumerated powers. The trial court held that Artis’s state-law claims were time barred because she had failed to file within § 1367(d)’s 30-day grace period. On appeal, the appellate court affirmed. The United States Supreme Court granted certiorari.